MR. ENNIS: Your Honor, I move that Plaintiffs' Exhibit Ninety-eight for identification be received in evidence.

THE COURT: It will be received.

MR. ENNIS:. (Continuing)

Q: When and where did you receive your Ph.D.?

A: The University of California at Berkeley in 1963 in the field of geology.

Q: What is your current employment?

A: I am presently employed as the assistant chief geologist for the western region of the United States Geological Survey, and I am one of three assistant chief geologists for the three regions of the United States. The western region includes the eight western states in the Pacific coast territory.

Q: Were you responsible for scientific testing of the lunar rock samples returned from the moon?

A: Yes. I was selected by NASA to be one of the principal investigators for the lunar rocks returned by the Apollo Eleven through Thirteen missions.

A: Well, geochronology includes methods that are used to determine the ages of geological events.

Q: Have you published a substantial number of books and articles in these fields?

A: Yes. Over a hundred scientific papers and a book that is commonly used as a textbook in radiometric dating classes.

MR. ENNIS: Your Honor, I offer Doctor Dalrymple as an expert in the fields of geology, geochronology, paleomagnetism and radiometric dating techniques in general.

MR. WILLIAMS: No objection.

THE COURT: Okay.

MR. ENNIS: (Continuing)

Q: Doctor Dalrymple, I have just handed you a copy of Act 590. Have you had an opportunity to read Act 590?

A: Yes, I have.

Q: Is there anything in the Act's definition of creation science to which the field of geochronology is relevant?

A: Yes. Section 4(a)(6) specifies, and I quote, A relatively recent inception of the earth and living kinds, end of quote.

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Q: Is there anything in the Act's definition of evolution to which the field of geochronology is relevant?

A: Yes. Section 4(b)(6) specifies, quote, An inception several billion years ago of the earth and somewhat later of life, end of quote.

Q: Are you familiar with the creation science literature concerning the age of the earth?

A: Yes, I am. I have read perhaps two dozen books and articles either in whole or in part. They consistently assert that the earth is somewhere between six and about twenty thousand years, with most of the literature saying that the earth is less than ten thousand years old.

Q: Are you aware of any scientific evidence to indicate that the earth is no more than ten thousand years old?

A: None whatsoever. In over twenty years of research and reading of scientific literature, I have never encountered any such evidence.

Q: Are you aware of any scientific evidence to indicate the earth is no more than ten million years old?

A: None whatsoever.

THE COURT: Wait a second. What is it that the creation scientists say is the age of the earth?

A: They make a variety of estimates. They range between about six and about twenty thousand years, from

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A: (Continuing) what I've read. Most of them assert rather persistently that the earth is less than ten thousand years. Beyond that they are not terribly specific.

Q: Are you aware of any scientific evidence to indicate the earth is no more than ten million years old?

A: None whatsoever.

Q: Are you aware of any scientific evidence to indicate a relatively young earth or a relatively recent inception of the earth?

A: None whatsoever.

Q: If you were required to teach the scientific evidences for a young earth, what would you teach?

A: Since there is no evidence for a young earth, I'm afraid the course would be without content. I would have nothing to teach at all.

Q: Is the assertion by creation scientists that the earth is relatively young subject to scientific testing?

A: Yes, it is. It one of the few assertions by the creationists that is subject to testing and falsification.

Q: Have such tests been conducted?

A: Yes. Many times, by many different methods over the last several decades.

Q: What do those tests show?

A: Those tests consistently show that the concept of a young earth is false; that the earth is billions of years

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A: (Continuing) old. In fact, the best figure for the earth is in the nature of four and a half billion years.

And I would like to point out that we're not talking about just the factor of two or small differences. The creationists estimates of the age of the earth are off by a factor of about four hundred fifty thousand.

Q: In your professional opinion, are the creation scientists assertions of a young earth been falsified?

A: Absolutely. I'd put them in the same category as the flat earth hypothesis and the hypothesis that the sun goes around the earth. I think those are all absurd, completely disproven hypotheses.

Q: In your professional opinion, in light of all of the scientific evidence, is the continued assertion by creation scientists that the earth is relatively young consistent with the scientific method?

A: No, it is not consistent with the scientific method to hold onto a hypothesis that has been completely disproven to the extent that it is now absurd.

Q: How do geochronologists test for the age of the earth?

A: We use what are called the radiometric dating techniques.

Q: Would you tell us very briefly, and we'll come back to the details later, how radiometric dating techniques work?

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A: Yes. Basically we rely on the radioactive decay of long lived radioactive isotopes into isotopes of another element. By convention we call the long lived isotopes that's doing the decaying the parent, and the end product we call the daughter.

What we do in principal is we measure the amount of parent isotopes in a rock or mineral and we measure the amount of the daughter isotope in a rock or mineral, and knowing the rate at which the decay is taking place, we can then calculate the age.

It is considerably more complicated than that, but that's the essence of those techniques.

Q: Are these isotopes, isotopes of various atoms?

A: Yes, they are.

Q: Could you briefly tell the Court what an atom is, how it's composed?

A: Well, an atom consists of basically three particles. The nucleus, or inner core of the atom, has both neutrons and protons. The number of protons in the nucleus determines what the chemical element for that atom is. Both neutrons and protons have the same mass.

Neutrons have no charge. The number of neutrons in an atom do not determine the elemental characteristics of that atom, only the number of protons. Orbiting the nucleus of the atom is a cloud of electrons

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A: (Continuing) that orbit more or less like the planets around the sun.

Q: Could you tell us briefly what an isotope is?

A: Yes. Differing atoms of the same element that have different numbers of neutrons in a nucleus are called isotopes of that particular element. The addition of a neutron, more or less, as I said, does not change the character of the element, it only changes the atomic mass. And in some cases, when several neutrons are added to the nucleus, the atom becomes unstable and becomes radioactive.

Q: Could you give an example of an isotope?

A: Yes. Carbon-14, for example. The element, Carbon, normally contains six protons. Ordinary carbon contains six neutrons, as well, giving it an atomic mass of twelve. That is usually indicated by the capital letter C, for carbon, and the superscript in the upper left hand corner denotes it being Carbon-12 for the atomic mass. If we add two neutrons to that atom, it can become Carbon-14, which is designated C-14.

Carbon-14, because of those two extra neutrons, is unstable and is radioactive, whereas Carbon-12 is not radioactive.

Q: Why did geochronologists rely upon radiometric dating techniques rather than other techniques?

A: Because radioactivity is the only process that we

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A: (Continuing) know of that's been constant through time for billions of years.

Q: Is radioactive decay affected by external factors?

A: No, radioactive decay is not affected by external factors. That's one reason we think it's been constant for a long time.

Q: Could you give an example of processes that are affected by external factors.

A: Yes. Examples would be the rates of erosion or the rates of sedimentation. That is the rate that sediments are deposited into the oceans and lakes. Both of those processes are affected by the amount of annual and daily rainfall, they are affected by the height of the continents above sea level, they are affected by the amount of wind, and so forth.

We know that all those factors vary with time, both on a daily and annual basis, and, therefore, the rates are not constant. They can't be used to calculate ages of any sort.

Q: Do creation scientists rely on the rates of erosion or sedimentation in their attempts to date the age of the earth?

A: Yes. In some of their literature they have used both of those techniques, and that is a good example of how unscientific some of their estimates are, because

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A: (Continuing) again, these processes have not been constant over time.

Q: Could you tell us why radioactive decay rates are basically impervious to external factors?

A: It's basically because the nucleus of an atom is extremely well protected from its surroundings. And also because radioactive decay is a spontaneous process that arises only from the nucleus; it's not affected by external factors. The cloud of electrons that surrounds the nucleus of an atom provides very good protection against external forces. And also the strength of the nuclear glue, the strength of the nuclear binding, is among the strongest forces in nature. This is one reason why scientists have to use powerful and extensive accelerators in atomic reactors to penetrate the nucleus of an atom. It's really tough to get in there.

Q: Have scientists tested and measured those decay rates under various circumstances to see whether they would be affected by external forces?

A: Yes. There has been a variety of tests over the past number of decades addressing exactly that point. And they found, for example, that decay rates do not change with extremes of temperature, from a hundred ninety-six degrees below zero Centigrade to two thousand degrees

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A: (Continuing) Centigrade. The rates were not affected.

At pressures of a vacuum or two thousand atmosphere, for example, thirty thousand pounds per square inch, we found that the combining of radioactive isotopes in different chemical compounds does not affect the decay rates.

Q: Have any tests ever shown any change in the decay rates of any of the particular isotopes geochronologists use in radiometric dating?

A: None. They've always been found to be constant.

Q: Are changes in decay rates of various isotopes at least theoretically possible?

A: Yes. Theoretically in some instances, and let me explain that. There are three principal types of decay involved in radioactive dating techniques. One is alpha decay. That's the decay that involves the ejection of an alpha particle from the nucleus of the atom. Another is beta decay. That involves the injection of something like an electron - it's called a beta particle - from the nucleus.

Theory tells us that neither of those types of decay can be affected by external factors, and in fact, none of the experiments have ever shown any effect on either alpha or beta decay.

There is a third type of decay called electron capture,

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A: (Continuing) where an orbital electron falls into the nucleus and converts a proton into a neutron. That type of radioactive decay, because the original electron comes from the electron shell, one can imagine if you depress that shell a little bit, you might increase the probability of the electron falling into the nucleus.

Theory tells us that such changes in electron capture decay are possible, but theory also tells us that those changes should be very small. And in fact, the maximum changes ever detected or ever forced have been the Beryllium-7, and that changes only one-tenth of one percent. No larger.

There have never been any changes affecting any of the decays being used for radioactive dating.

Q: Do creation scientists challenge the constancy of those radioactive decay processes?

A: Yes, they do. There have done that on a number of occasions.

Q: Have they advanced any scientific evidence to support their challenge?

A: None whatsoever.

Q: Did they use the relevant data on the decay rates in a fair and objective manner, in your professional opinion?

A: Yes, I can give two examples. The first is in an Institute for Creation Research technical monograph written by Harold Slusher entitled, I believe, A Critique of Radiometric Dating.

In that publication he makes the statement that the decay rates of Iron-57 have been changed by as much as three percent by strong electric fields. The problem with that is that Iron-57 is not radioactive. Iron-57 is a stable isotope. When Iron-57, it does undergo an internal conversion decay, and by that I mean simply a mechanism for getting rid of some excess energy. And that type of decay does also have a decay rate, but it's completely irrelevant to radioactive dating.

So when Iron-57 decays, "by internal conversion", it remains Iron-57. One of the dating schemes used in geology involved internal conversions. So the example of Iron-57 cited by Slusher is simply irrelevant.

And in fact, he did reference his source of that data, and I've been unable to confirm the fact that Iron-57 decay rates by internal conversion have been changed, so I'm not sure that's even true.

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Q: But even if it were true, it would be irrelevant because Iron-57 would remain Iron-57?

A: That's exactly right.

Q: And the isotope techniques you rely upon are changed from one element to another?

A: That's true.

Q: Could you give, another example?

A: Yes. Another example frequently cited is the use of neutrinos. They frequently claim that neutrinos might change decay rates. There are several things wrong with that hypothesis also. The first thing, the source of their statement was a column in Industrial Research by Frederich Houtermanns entitled Speculative Science or something. Scientific Speculation is the title of his column.

And without any empirical evidence whatsoever, Houtermanns speculated the neutrinos might somehow effect radioactive clocks. But there is no theory for that and there is no empirical evidence that such is the case.

The creationists conveniently leave out the speculative nature of that particular idea. The second thing is that neutrinos are extremely small particles. They have virtually no mass or little mass and no charge. They were first postulated by Pauli back in the 1930's as a way of an atom carrying off excess energy

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A: (Continuing) when it decays by beta decay. They interact so little with matter, in fact, that they're very difficult to detect, and it's several decades later before they were even detected. Neutrinos can pass completely through the earth without interacting with the matter, and there's no reason at all to suspect that they would change the decay rates or alter the decay rates in any way.

Finally, the creationists typically argue that neutrinos might reset the atomic clock. I am not quite sure what they mean by that, but if it's used in the usual sense, to reset a clock means starting it back at zero. The effect of that would be that all of our radiometric dating techniques would overestimate the geologic ages and ages of the earth, not underestimate them. So that works against their hypothesis.

Q: If they reset the clocks, then the test results from that resetting would show the earth to be younger than in fact?

A: Yes. What, in fact, we would have would be a minimum age instead of a correct age. So it works in exactly the opposite direction.

Q: In addition to questioning the constancy of the decay rates, do creation scientists make other criticisms of radiometric dating?

A: Yes. One of their other criticisms is that your

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A: (Continuing) parent or daughter isotopes might be either added or subtracted from the rock between the time of its formation and the time it would be measured. And they commonly say that since we can't know whether or not the daughter or parent isotopes have been added or subtracted, therefore, we have no basis for assuming they are not, or for calculating an age from this data.

Q: Is that commonly referred to as the closed system-open system problem?

A: Yes. Basically all radiometric dating techniques require - most of them do, not all - most of them require that the rock system, the piece of rock or the mineral they were measuring, has been a closed system since the time of crystallization up until the time that we measure.

And what they're basically saying is that we have no way of knowing whether they have been a closed system or not.

Q: What steps do geochronologists take to insure that the samples they test have remained closed systems and have not changed since they were initially formed?

A: We try to be fairly careful with that. We don't run out and pick up just any rock and subject it to these expensive and time consuming tests. There are several different ways we go about this. The first thing is, we can observe the geological circumstances in which the

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A: (Continuing) sample occurs. And that tells us a lot about the history of that sample, what kinds of external factors it might have been subjected to. The second thing is that there are microscopic techniques that we can use to examine the rock in detail and tell, whether or not it's likely to have been a closed system since its formation.

You see, all things that can affect the rock system in terms of opening it also leave other evidence behind, like changes in minerals that we can observe. So we have pretty good field and laboratory techniques which will tell in advance whether a system has been a closed system or an open system.

Q: Do you, yourself, engage in that testing process?

A: Oh, yes, all the time. As a result, I personally reject perhaps a half to three-quarters of all samples for dating just for that very reason that the samples are not suitable. This rejection is done before we get any results.

Q: Once you have a sample which you believe has not changed since formation, is there any objective way to test a sample to determine whether you're right or wrong?

A: Yes. There are a number of objective ways to do that. These ways rely on the results themselves.

Q: Do the results themselves show whether the sample has changed its formation?

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A: Yes, they do.

Q: If the results of a test showed that a sample had changed since formation, is that sample then utterly worthless?

A: No, not at all. We are not always interested in the age of the rock, For example, sometime we are interested in the age of the heating events. If, for example, a rock body has been subjected to heating, we might be more interested in what event caused that heating than the usual crystallization age of the rock, so that usually these kinds of results give us other kinds of information.

They also tell us a good deal about the state of that sample, whether or not it has been an open or closed system. So just because we don't get a reliable crystallization age doesn't mean that we aren't getting other information.

For example, we might end up with the age of the heating events which would be an extremely valuable piece of information. Sometimes just knowing the sample has not been a closed system is an extremely valuable piece of information.

So we use these dating techniques for lots of things other than determining the age of the rock sample.

Q: How many methods are there for determining

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Q: (Continuing) subjectively whether a sample has been changed since formation?

A: Well, there are quite a variety, but I think they can be lumped into about four categories. Those include dating two minerals from the same rock; using two different techniques on the same rock; other tests that Are called geological consistency tests, and finally, there is a category of techniques called isochron techniques that also serve that purpose.

Q: Could you briefly describe the first method?

A: Yes. In dating of two minerals from the same rock, the reason we do that is because different minerals respond in different ways to external factors.

For example, in the potassium argon method, the daughter product is argon, which is a rare gas. It's not terribly happy being inside minerals. It doesn't chemically combine with any of the other elements there.

If we take the mineral biotite, that's a mica, for example, and date that with the potassium argon method, then we also date the mineral hornblende with the potassium argon method, if there has been an external influence on this system, we expect those two minerals to respond differently.

This is because the biotite would start to release its argon at temperatures of perhaps two-fifty to three

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A: (Continuing) hundred degrees centigrade, whereas the hornblende would reach six or seven hundred degrees centigrade before it starts to release its argon.

There, of course, has been a heating event of, let's say hypothetically five hundred degrees, we would expect to see argon loss or younger ages from the biotites, whereas the hornblende might retain all of its argon completely.

The main point is that when we get a discrepancy like this, we know that something has happened to the system that made it, violate our assumption of a closed system, and that's valuable information.

Q: And if you get that result, you then do not use that sample to postulate an age for the initial formation of the samples?

A: That's right. The results themselves tell us that that would be a very dangerous conclusion to come to. But we can postulate that there has been something happen to that rock.

Q: Go to the second method you use.

A: The second method involves using two different dating techniques on the same rock. This has a couple of advantages. It's a little more powerful than the first method.

For example, if we use the potassium argon method, which has a half life of one point two five billion years, and

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A: (Continuing) we use the rubidium strontium method, which has a half life of forty-eight point eight billion years, we essentially have two clocks running at different speeds but keeping the same time.

If I could use an analogy, we might have two wristwatches. One wristwatch might use a balance wheel that rotates back and forth five times a second. On the other hand we might have a digital watch that uses a little quartz crystal that operates at a speed of, let's say, twenty thousand times a second. We, then, have two watches that are ticking at different rates but keeping the same time. That same advantage accrues to using two different methods on the same rock.

The second advantage is the daughter products are different. The daughter product of the potassium argon method is argon. It's a rare gas. It behaves quite differently to heating, whether in alteration, than does strontium-87, which is the daughter product of the rubidium strontium method. Strontium-87 is not a gas, it's a chemical element that likes to be in chemical combination with certain other things in a rock.

So again we expect a different response.

Q: Does testing a sample with the two or more techniques frequently yield the same age for that sample?

A: Yes. Particularly in the cases where we know from

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A: (Continuing) other evidence that the sample has been undisturbed, we commonly get that result.

Q: What do creation scientists say about age agreements between different techniques?

A: Well, they usually just ignore them. They don't pay any attention to them at all.

Q: Does testing a sample with two or more techniques ever yield different rates for that sample?

A: Yes. Quite often it does.

Q: What do creation scientists say about those age disagreements?

A: Well, they usually use those disagreements and purport that they have evidence that the techniques don't work.

Q: Is that a scientific assessment of the evidence?

A: Well, no. There are several things wrong with that. In the first place, when we get disagreements, they are almost invariably caused by some external factor that has caused one of the clocks to read in a way that's too young. It gives us an age that is too young.

The second thing is that age that is too young might measure, for example, the age of the event. Those ages that are too young are still millions and millions of years old, which, even though we don't have agreement between the techniques, still contradict the hypothesis

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A: (Continuing) of an earth less than ten thousand years old.

Finally, the reason for doing these kinds of tests is to determine in advance upon the results themselves whether or not the technique is reliable. Therefore, they are using our very test method as a criticism of the method itself, and I sort of consider that dirty pool. It's not very honest.

Q: What's the third method commonly used to test the changes in a sample?

A: Well, the third method involves geological consistency. Rocks don't occur all by themselves. They usually are surrounded by other rocks, and the relationship of the sample to these other rocks can be determined.

Perhaps the simplest example might be a lava flow. If we have a stack of lava flows from a volcano and we are interested in determining the age of that volcano or that stack of lava flows, we wouldn't just date one rock. We would date one from the top of the sequence, perhaps; we would date one from the bottom of the sequence, and we might date eight or ten intermediate in the sequence. We know because of the way lava flows form, one on top of the other, that all of those ages should either be the same or they should become progressively older as you go

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A: (Continuing) down in the pile.

If, in fact, we get random or chaotic results, that tells us that something is wrong about our assumption of the closed system, so we can use a variety of geological consistency tests like this to test the results as well.

Q: What is the fourth method that you rely upon?

A: Well, the fourth is really a family of methods called isochron techniques.

Q: How do the isochron techniques differ from the other techniques you've just mentioned?

A: These are techniques that have especially built in checks and balances, so that we can tell from the results themselves, without making any other assumptions, whether or not the techniques are giving reliable ages.

Some isochron techniques really work very well, and work best on open systems. Isochron techniques typically yield two important results. One is, most of the isochron techniques are able to tell us the amount and composition of any initial daughter that is present. That's not something we need to assume, it's something that falls out of the calculations.

The second thing is that the isochron techniques tell us very clearly whether a sample has been opened or closed. If the sample is still an isochron, then we know that that

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A: (Continuing) sample is a good closed system. If we don't get an isochron, we know that something is wrong with the sample. And we get these results just from the experimental data themselves, without any other geological consideration.

So they are ultimately self-checking, and they are one of the most common, surefire ways to date rocks.

Q: Have creation scientist's produced any evidence or suggested any plausible theory to support their assertion that the earth is only about ten thousand years old?

A: No. I know of no plausible theory that they suggest. They have proposed several methods that don't work.

Q: Have you looked into the creation science claim that the decay of the earth's magnetic field shows a young earth?

A: Yes. I've looked into that in some detail. That is rather fully described in an Institute for Creation Research technical monograph by Thomas Barnes, which if I recall correctly is titled The Origin and Destiny of the Earth's Magnetic Field.

Let me try to explain briefly what Barnes asserts. For the last hundred and fifty years or so, since 1835, scientists have analyzed the earth's magnetic field, and they have noticed that the dipole moment, and we can think

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A: (Continuing) of that just as the strength of the main magnetic field, has decreased, and it has decreased in intensity over the last hundred and fifty years.

The decrease amounts to about six or seven percent. Barnes claims that the earth's magnetic fields are decaying remnants of a field that was originally created at the time the earth was created, and that it is irreversible decaying and will eventually vanish, in about nine or ten thousand years.

What Barnes does is assume that this decay is exponential. Actually you can't tell whether it's exponential within the earth, but he assumes it's exponential going back to a hypothesis proposed by, actually a model proposed by Sir Forrest Land back in the eighteen hundreds.

Land is not talking about the magnetic field, though. He gives the mathematical calculations that Barnes uses. Barnes then calculates a half life with this presumed exponential decay, extrapolates backwards in time and concludes that in 8000 B.C. the strength of the earth's dipole moment would have been the same as the strength of the magnetic star.

And since that is obviously absurd, and I would have to agree that that would be absurd, therefore, the earth must be less than ten thousand years old.

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Q: What is wrong with that claim?

A: Well, there are quite a few things wrong with that claim. To start with, Barnes only considers the dipole field. The earth's magnetic field, to a first approximation, is like a dipole. That is, it produces the same field as would a large bar magnet, roughly parallel to the axis of rotation of the earth, lining across the merging poles, circle around the earth, and return back in at the other pole. But that's not the whole story. That's only the part that Barnes works with.

The other component of the magnetic field is the non-dipole field. These are irregularities that are superimposed on the dipole field and amount to a considerable proportion of the total field.

Finally, theory tells us that there is probably another very large component of the magnetic field inside the core of the earth that we can't observe because the line of the flux are closed.

So Barnes makes several mistakes. First, he equates the dipole field with the total earth's field, which it's not. It's only a part of the earth's field. And second, he equates the dipole field strength with the total magnetic energy. And both of those extrapolations are completely unjustified.

Careful studies of the non-dipole and dipole field over

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A: (Continuing) the past fifty years have shown that the decrease in the dipole field is exactly balanced by an increase in the strength of the non-dipole field.

In fact, over the last fifty years, as far as we can tell, there has been no decay in total field energy external to the core at all. Similar studies over the last hundred and twenty years show a very slight decrease in the total field energy external to the core. So in fact, we don't know exactly what's happening to the total field energy.

And finally, paleomagnetic observations have shown that the strength of the dipole moment doesn't decrease continually in one direction, but it oscillates with periods of a few thousand years. So it goes up for a while and goes down for a while. At the same time the non-dipole field is also changing.

And lastly, he completely ignores geomagnetic reversals. Paleomagnetic studies of rocks have shown conclusively that the earth's field has periodically, in the past, reversed polarities, so that the North Pole becomes the South Pole, and vice versa. This happens rather frequently geologically, that is, hundreds of thousands to millions of years at a time.

We now have a pretty good time scale for those reversals over the last ninety million years. And Barnes completely

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A: (Continuing) ignores that evidence.

One thing we do know about geomagnetic reversals from the evidence, of rocks is that during the process of the field reversing, the dipole moment decays.

Q: What do creation scientists say about the possibility of the polarity reversals?

A: Well, they claim that they can't happen, and they claim that they have not happened.

Q: Is there any basis for that claim?

A: No, none whatsoever. The paleomagnetic evidence is very sound, and, in fact, it's verified by other evidence as well.

It's also interesting to note that the earth's field is not the only field that reverses polarity. For example, in 1953, the dipole field of the sun was positive polarity in the North and negative polarity in the South pole. Over the next few years the strength of the sun's dipole field began to decrease, very much in the same way that the strengths of the earth's dipole field is now decreasing, until within a few years it had vanished entirely. It couldn't be measured from the earth.

Then gradually it began to reestablish itself, and by 1958 the sun's dipole field was completely reversed, so that the North Pole, instead of being positive, was now negative, and vice versa for the South Pole.

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A: (Continuing) So geomagnetic reversals are not a surprising phenomena, and in fact, they are expected. Magnetic reversals have also been seen in the stars.

Q: But creation scientists just deny that that happens?

A: Well, they never mention that. It's simply ignored.

Q: Do creation science arguments for a young earth rely on the cooling of the earth?

A: Yes. They commonly use that argument. And again, that argument is one that has been championed by Thomas Barnes and some of the patrons of the Institute of Creation Research.

That particular theory, or idea, goes back to an idea championed by Lord Kelvin (Thomson) who started in the mid-eighteen hundreds. At that time you must remember that there was no such thing as radioactivity. By that I mean it had not been discovered yet.

Kelvin observed that the temperature of the earth increased as it went downward from the surface. That is, he observed the geothermal gradient. He had started with the assumption that the earth started from a white hot incandescent sphere and it cooled to its present state. So he calculated how long that would take.

His first estimates were something between twenty and four hundred million years. Later he settled on twenty-four million years, which was not his figure, but

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A: (Continuing) it was a figure that was first calculated by the geologist Clarence King, who quite incidentally was the first director of the Geological Survey.

The problem with total analysis in Barnes championing of this thing is that partly he took a physical way to calculate the age of the earth. The problem with that is that in 1903 Rutherford and Soddy demonstrated conclusively that there's an enormous amount of energy available in radioactive decay. In fact, all of the heat now pouring outward from the earth can be accounted for solely by radioactive elements in the earth's crust and mantle.

Kelvin never publicly recanted his views, but in the history of his life it has been recorded that he privately

Admitted that the discovery by Rutherford and Soddy that said this enormous energy is from radioactive decay had completely disproved his hypothesis. Even Kelvin knew it was wrong.

It's quite amazing to me that the creationists would hold such an idea for a couple of reasons. The first reason being that we've known for all these centuries that Kelvin's calculations were completely irrelevant. And the second thing is that Kelvin thought the earth was billions of years old.

Q: Do creation scientists rely on the accumulation of meteor dust as evidence for a young age of the earth?

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A: Yes. That's another one that they claim. And I've looked into it some, and if you don't mind, I'd like to refer to some notes on that so that I get the figures straight.

Q: Could you explain that creation science claim?

A: Yes. Morris, in 1974, and also a book by Wysong in 1966, both claim that there's evidence that the influx of meteoric dust to the earth is fourteen million tons per year.

And they calculate that if the earth were five billion years old, this should result in a layer of meteoric dust on the earth a hundred and eight-five feet thick. And they say, "How absurd, we don't observe this," of course.

There are some problems with that, however. They are relying on calculations done by a man by the name of Peterson in 1960. What Peterson did was collect volumes of air from the top of Mauna Loa volcano in Hawaii, using a pump originally developed for smog, I believe.

Then he thought about the dust. Then he analyzed this dust for nickel content. He observed that nickel was a fairly rare element on the earth's crust. That's not exactly true, but that was the assumption that he used.

And he assumed that the meteoric dust had a nickel content of two and half percent. So using the mass of dust that he had and the nickel content of the dust and an

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A: (Continuing) assumed two and a half percent nickel content for meteoric material, he was able to calculate the annual volume of meteoric dust that flowed into the earth.

He came up with a figure of about fifteen million tons per year, but when he weighed all of the evidence, he finally concluded that perhaps, about five million tons per year was about right.

Morris, on the other hand, and Wysong, both choose thehigher number, I think because that makes the layer of dust thicker.

The problem with that is that nickel is not all that uncommon in the earth's crust, and probably Peterson was measuring a lot of contamination.

There have been more recent estimates than Peterson's. In 1968, for example, Barker and Anders made an estimate of the meteoric influx of cosmic dust based on the uranium osmium contents, which are extremely rare, of matter in deep sea sediments. And they came up with an influx figure that was a factor of twenty-three lower than Peterson's figure, and, therefore, twenty-three times lower than the figure used by Morris.

Probably the best completely independent estimates, however, are based on satellite data, satellite penetration data. That is, the number and the mass of particles distract satellites as they orbit the earth.

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A: (Continuing) And NASA collected quite a bit of these data in the 1960's.

There was a review of that done in 1972, and you note that that information was available when Morris and Wysong wrote their book, but they didn't cite it.

Q: What does that NASA data show?

A: Well, that showed that the influx of meteoric materials was, in fact, not fourteen million tons or even five million tons per year, but more like eleven thousand tons per year. In other words, two orders of magnitude lower.

And coming out here on the plane, I redid Morris' calculations using these better figures, and I came up with a rough layer of four point six centimeters in five billion years. And of course, with the rainfall and everything, that simply would have been washed away.

There's an interesting aside. NASA was quite concerned about the layer of dust on the moon. NASA estimated that it would produce a layer of dust on the moon in four and a half billion years of about one and half to perhaps fifteen centimeters maximum. And in the least disturbed areas of the moon, the astronauts measured a thickness of about ten centimeters, so the observations agree exactly with the predictions.

Q: Do these observations on the moon prove that the

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Q: (Continuing) earth or the moon are, in fact, four point five to five million years old?

A: No, they don't prove anything whatsoever except that there's dust on the moon. It's another one of those processes that has a non-constant rate. We have more reason to suspect that the rate of influx of meteoric dust has been constant with time. In fact, we have a lot of reasons to suspect that it is not.

For example, in the early history of the earth, four and a half billion years ago when the earth was first formed, it was sweeping up out of space enormous amounts of material. During those periods of the earth's history, we would expect the influx rate to be very, very high. Now it's much lower.

The evidence indicates it has probably been constant for perhaps the last ten million years. We have no idea what the rate of influx of meteoric dust has been over geologic history. So it's one of these things that you simply can't use.

Q: Do creation scientists rely upon the shrinking of the sun?

A: Yes. That's another one I've read, and that stems from a paper, I think in the Institute of Creation Research Impact, Number 82, published in April of 1980. Their claim is based on a paper by Eddie Inpornasian (Aram Boornazian) which was published in 1979. Using

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A: (Continuing) visual observations of the sun, Aram Boornazian observed that they thought that the sun's diameter was decreasing. And it was decreasing at such a rate that in a hundred thousand years the sun would vanish to a point.

And the creationists work this backwards and say that if the earth was as old as geologists claim it was, then the sun would have been very large in the past history, and would have been so large that life would not have been possible on the earth.

The problem with this particular calculation is that the original data of Aram Boornazian was completely wrong. There had been another study done by Irwin Shapiro of MIT, who used twenty-three transits of mercury across the face of the sun that occurred between 1736 and sometime within the last few years, a much more accurate way to measure the diameter of the sun than the techniques used by Aram and his colleagues. Shapiro, his paper was published in 1980. He said rather conclusively that the sun's diameter is not changing at all. The sun is not shrinking or it's not growing.

Q: Are you aware of other supposed tests for the earth's age proposed by creation scientists?

A: Yes. There are a number of them in a book by Morris called, I believe, The Scientific Case for Creation. As I recall, he proposes about seventy

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A: (Continuing) different methods that he lists. They ranged all the way from influx of soda aluminum into the oceans, for which he gets a figure of a hundred years, I believe, to influx of magma into the crust, for which he gets a figure of five hundred million years.

MR. ENNIS: Your Honor, Plaintiffs have previously marked for identification excerpts from that particular book that include approximately six pages to which Doctor Dalrymple might refer in his testimony. I have given copies of those additional six pages to the Attorney General.

If there is no objection, I'd like for those six pages to be added and included with Plaintiffs' Exhibit Eighty-Six for identification.

THE COURT: Okay.

MR. ENNIS: (Continuing)

Q: I'd like to show you Plaintiffs' Exhibit Eighty-Six for identification.

A: Okay.

Q: Does Mr. Morris, in that book, acknowledge any assumptions he used in deciding which of those tests to rely upon and which not to rely upon?

A: Yes, he does. On page 53 he makes the following statement: "It is equally legitimate for creationists to calculate apparent ages using assumptions which agree with

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A: (Continuing) their belief in special creation, provided they acknowledge that fact. And then he goes on to present seventy such calculations, most of which are made by him and his colleagues, but some of which he refers to the scientific literature.

Q: What do those seventy tests supposedly show?

A: Well, Morris approaches this in a rather strange way. He says, "I'm going to make all these calculations for the age of the earth using these assumptions," and then gets a variety of results, ranging from too small to measure, to, I don't know, five hundred million years, something like that.

And he says, "Look how inconsistent the results are. As you see, we really can't calculate the age of the earth." However, he thinks that the young ages are probably more reliable than the old ages, basically because there would have been less time for external factors to affect the calculation.

The problem with these seventy ages is that most of them rely on rates that are not constant. And these seventy also include things like the magnetic field and meteoric dust, which I have already discussed.

Sometimes, however, he uses very misleading and erroneous data.

Q: Could you give me an example of that?

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A: Yes, I can. There is one which is here, number thirty-three. It's entitled, "Formation of Carbon 14 on Meteorites." The age he lists is a hundred thousand years, and the reference he gives is to a paper published in 1972 by Boeckl. There is a problem with that, and that is that Boeckl's: paper was not about meteorites at all; Boeckl's paper was about tektites. Tektites are objects which are thought to originate on the earth.

The second thing was that Boeckl was interested in calculating the cosmic rays exposure ages for these tektites. He wanted to know how long they had spent in space.

In order to make the calculations he was trying to make, he had to assume an initial age for the tektites. His calculations were not terribly sensitive at all to what he assumed, so he just assumed ten thousand years for his particular purpose.

I don't know where Morris got a hundred thousand years. That figure he must have made up. But the fact is that Boeckl's paper wasn't about the subject Morris claims it was. There was no data in Boeckl's paper that could be used to calculate the age of the earth or anything else.

The one age that Boeckl was trying to calculate was the residence time of these objects in space, and that's all. So this is truly misleading and very unscientific.

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Q: Doctor Dalrymple, in conclusion, in your professional opinion, is there any scientific evidence which indicates a relatively recent inception of the earth?

A: There is none whatsoever.

MR. ENNIS: I have no further questions, Your Honor.

THE COURT: I think we probably ought to recess for the night. How long do you think your cross examination is going to be?

MR. WILLIAMS: Not very long, your Honor.

THE COURT: You are talking about five or ten minutes?

MR. WILLIAMS: It will be a little longer. Might take twenty minutes, or under.

THE COURT: Why don't we wait until tomorrow to do it if you don't mind.

I found out today that GSA recalculated the cost of driving an automobile, and it is not twenty-two and a half cents a mile like they were paying us; it is twenty cents a mile. And you can find some comfort in that, but I think I am going to protest by quitting early today.

(9:00 a.m.) THE COURT: I see you all made it back, and I believe we are about to begin the cross examination of Doctor Dalrymple.

CROSS EXAMINATION

BY MR. WILLIAMS:

Q: Is constancy of the rate of radioactive decay a requirement for radiometric dating?

A: Yes. It is required that radiometric dating be based on constant decay rates, at least within limits of significant areas, and what I mean by that is that if the decay rates were to change a percent or two, that would probably not significantly alter any of our major conclusions in geology.

Q: To the best of your knowledge, has the rate of radioactive decay always been constant?

A: As far as we know from all the evidence we have, it has always been constant. We have no, either empirical or theoretical reason to believe it is not.

Q: So as far as you know, it would have been constant one billion years ago, the same as it is today.

A: As far as we know.

Q: Five billion years ago?

A: As far as we know.

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Q: Ten billion years ago?

A: As far as we know.

Q: Fifteen billion?

A: I don't know how far back you want to take this, but I think for the purposes of geology and the age of the solar system, we are only interested in using radiometric dating on objects we can possess in our hand, so we only need to take that back about four and a half or five billion years.

I think whether it's been constant fifteen billion years is irrelevant, we have no way of getting samples that old. We can only sample things that have been in the solar system.

Q: How old is the solar system, to the best of your knowledge?

A: As far as we know, it is four and a half billion years old.

Q: The solar system itself?

A: The solar system itself. Now, when we talk about the age of something like the solar system, you have to understand that there was a finite period of time over which that system formed, and we may be talking about a period of a few hundred years, so it is not a precise point in time, but some interval, but compared with the age of the solar system, it is thought that that interval

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A: (Continuing) was probably rather short-a few percent.

Q: Are you aware of when those scientists hypothesized or when the so-called Big Bang occurred, how many years ago?

A: No, I am not sure exactly when that was supposed—

Q: Would the rate of radioactive decay have been constant at the time of the Big Bang?

A: I am not an astrophysicist. I don't know the conditions that existed in the so-called primordial bowl of soup, and so I am afraid I can't answer your question.

Q: So you don't have any opinion as to whether it was constant then?

A: That's out of my field of expertise. I can't even tell you whether there were atoms in the same sense that we use that term now.

Q: But you did state that it had always been constant as far as you knew, but now you state you don't know about the Big Bang, whether it was constant then; is that correct?

A: Well, what I said, it's been constant within the limits in which we are interested. For the purposes of radiometric dating it hardly matters whether it was constant at the moment of the Big Bang. Let me say this-

Q: I don't want to interrupt you.

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A: That's all right.

Q: You say as far as you are concerned, for the purposes of your concern it has been constant as far as you know, and your purposes go back to the age of the earth for four point five billion years; is that correct?

A: Yes, that's correct.

Q: But you base that age of the earth on the assumption or on this requirement that it has always been constant; is that correct?

A: That is not entirely- That's correct, but it is not an assumption. It is not fair to calculate it that way. In a certain sense it is an assumption, but that assumption has also been tested.

For example, if you look at the ages of the oldest, least disturbed meteorites, these objects give ages at one point five to four point six billion years. A variety of different radioactive decay schemes, schemes it at different half lives. They are based on different elements. They would not give those identical ages if the rate of decay had been constant.

Q: But do those schemes that you mentioned there rely upon the requirement that the rate of radioactive decay has always been constant as well?

A: Yes, they do.

Q: So all methods you know would rely upon this, what

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Q: (Continuing) you termed a requirement and what I termed an assumption; is that correct?

A: That is correct.

Q: The rate of decay is a statistical process, is it not? I think you testified yesterday to that.

A: Basically, it is.

Q: Would you agree that any deviation in the rate of decay would have to be accompanied by a change in physical laws?

A: As far as we know, any change in decay would have to be accompanied by a change in physical laws, with the exceptions that I mentioned yesterday. There are small changes known in certain kinds of decay, specifically in electron capture, a tenth of a percent.

Q: What do you consider the strongest evidence for the constant rate of radioactive decay?

A: Well, I don't think I could give you a single piece of strongest evidence, but I think the sum total of the evidence, if I can simplify it, is that rates of decay have been tested in the laboratory and found to be essentially invariant.

Theory tells us those rates of decay should be invariant. And when we are able to test those rates of decay on undisturbed systems; that is, systems that we have good reason to presume have been closed since their

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A: (Continuing) formation clear back to the oldest objects known in the solar system, we find we get consistent results using different decay schemes on isotopes that decay at different rates.

So that is essentially a synopsis of the evidence for constancy of decay.

Q: Did you say- but is it not true that as long- Well, if the rate of decay has varied and as long as the variation would have been uniform, would you still get these consistent results?

A: It is possible to propose a set of conditions under which you could get those consistent results.

THE COURT: Excuse me. I didn't understand that.

THE WITNESS: I think what he is saying is, is it possible to vary the decay rate in such a way that you could still get a consistent set of results by using different decay schemes, and I think it is always possible to propose such a set of circumstances, yes.

So that question is in the nature of a "what if", and one can always come to the conclusion that you can restructure science in such a way to make that "what if" happen. But that is not the sort of thing we usually do unless we have good reason to presume the physical laws have changed, and we presume they have not.

Testimony of Dr. G. Brent Dalrymple - Page 2

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THE WITNESS: (Continuing) gravitational constant and so forth. May I elaborate just a little bit more? We are not talking about small changes in decay. If the creation scientists are correct and the earth is only ten thousand years old, we are talking about many orders of magnitude, thousands of times difference. The difference between the age of the earth that scientists calculate and the age that the creationists calculate are different by a factor of four hundred and fifty thousand.

So you don't have to perturb the constancy of decay laws a little bit; you have to perturb them a lot.

MR. WILLIAMS: (Continuing)

Q: Where in Act 590 is the age of the earth listed as ten thousand years?

A: It is not listed as ten thousand years in 590.

Q: To you, as a geologist, would not an age of several hundred million years still be relatively recent?

A: That would be considered on the young side of middle age, yes.

THE COURT: Mr. Williams, while we are on that point, I have really been curious. What does the State contend a teacher is supposed to interpret that to mean- "relatively recent"? What is going to be your contention, if you are a biology teacher and the biology teacher tells the students about "relatively recent"?

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THE COURT: (Continuing) What does that mean?

MR. WILLIAMS: I think it means a couple of things. First of all, that there may be some doubt as to the reliability of some of the dating methods which are currently being used. Therefore, the generally accepted, as described by Doctor Dalrymple, age of four point five billion years may not be that certain.

I think, secondly, our testimony will show that because of this factor the age of the earth may, in fact, be somewhat younger. The State, I don't think, is tied to the age of ten thousand years as the plaintiff has tried to pin on Act 590.

Indeed, the age of the earth is probably, in terms of the overall creation science model, is probably, I would say, the least important of those. I am not sure how much the subject would come up in a biology class myself. I have some questions about it myself.

THE COURT: Apparently the Act directs that it come up. I'm curious about that.

MR. WILLIAMS: Well, your Honor, the Act directs that there be balanced treatment when there is scientific evidence on either side. And doesn't it require that all-

THE COURT: I assume that any biology course will address the age of the earth in some fashion, and they will, I think, talk about radioactive decay and that

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THE COURT: (Continuing) method of aging the world or judging the age of the world. And I gather the Act also directs the biology teacher to say something about a relatively recent formation of the earth, and I'm puzzled as to what the teacher is supposed to say.

Are they supposed to approach it in a negative fashion and say, "No, it's not four and a half billion years old"? And what if some student says, "Well, how old is it, then, under this model?" What would they say?

MR. WILLIAMS: Well, first of all, let me say that I'm not engaged in curriculum design or materials design, but as I understand it, I think that they could say that there are besides this, other sciences, first of all, who have some doubts as to this dating method. There are other competent scientists who believe that the earth might be, relatively speaking, to the four point five billion years, relatively speaking, younger than that. I don't think there is any one age which anyone would have to be taught as an alternative age. I think it would be a range of ages.

THE COURT: Well, again, what is that range, then?

MR. WILLIAMS: Well, your Honor, I would prefer, if we could, to defer that to the presentation of our testimony when we will get into that.

THE COURT: Maybe that would be best. It's just

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THE COURT: (Continuing) something that keeps occurring to me as we listen to the testimony here.

MR. WILLIAMS: (Continuing)

Q: Mr. Dalrymple, is it correct that you think that geochronology establishes an age of the earth, not only that the earth is several million years old, but also establishes the age of the fossils which are enclosed in the rocks?

A: Yes. That's correct.

Q: Is there any reliable method for gauging fossils themselves that you are aware of?

A: You mean dating the fossil specifically?

Q: Yes.

A: There is one method, but it does not go back very far, and that's Carbon-14. The rest of the fossils on the record are done by dating primarily igneous rocks that are in known relationship to fossils. By an igneous rock, I mean a rock that's cooled from a melt, like a lava flow or granite.

Q: How old would you say that geochronology establishes the ages of the oldest fossils?

A: Well, the oldest fossils that I know of - And I'm not a paleontologist; I'm going to have to give you a semi-layman's answer - that I know of are bacteria that are found in certain shales in, I believe, Africa or South

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A: (Continuing) Africa. And if I remember correctly, those are close to three billion years old.

Q: You say you're not a paleontologist and you give a lay answer, but the method of dating fossils actually relies upon the dating of certain rocks around the fossil, does it not?

A: Well, not necessarily the rocks that actually enclose the fossil, because most of the dating technicians work on igneous rock or metamorphic rocks, that is, crystalline rocks in which fossils don't occur.

But again, to take a simple case, if we had a sedimentary bed that includes fossils and we have a lava flow beneath that bed and another lava flow on top of that bed. And if we date those two lava flows, then we have sensibly dated the age of that fossil, or at least we have bracketed the age of that fossil.

That's the general way in which fossils are dated radiometrically.

Q: Now, do you understand that biologists consider these fossils enclosed in these rocks to be the relics or the remnants of some evolutionary development?

A: Well, I think the fossils are relics of an animal.

Q: Would that be the evidence of the evolutionary development?

A: Well, as far as I know, yes.

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Q: Then would it be fair to say in your mind that the ages for the various types of fossils have been most precisely determined or measured by radioactive dating or by geochronology?

A: That sounds like a fair statement.

Q: Since geochronology does play such an important role on the ages of the rocks and the fossils, would you agree that it would be important to know whether there is any evidence which exists which would bear on the fundamental premises of geochronology?

A: Of course. Let me add that that's a subject that's been discussed considerably in scientific literature. We're always searching for that sort of thing. That's a much debated question

Q: I think you said yesterday that anyone who believes. in a young age of the earth, in your opinion, to be not too bright scientifically, and are in the same category as people who believe that the earth is flat?

A: Yes. I think if we are talking about people who profess to be scientists and insist on ignoring what the actual evidence is for the age of the earth, then I find it difficult to think that their thought processes are straight.

Q: Is it true that you do not know of any scientists who would not agree with you, with your viewpoint on this

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Q: (Continuing) radioactive dating and of the age of the earth and fossils?

A: Will you rephrase that? I'm not sure I understand it.

Q: Is it true that you stated, I think in your deposition, that you do not know of any scientist-

MR. WILLIAMS: I'm not referring to a page at this point, I'm asking a question.

MR. WILLIAMS: (Continuing)

Q: Is it true that you do not know of any scientist who does not agree with you and your view point and opinion as to the age of the earth and the fossils?

A: It depends on who you include in the word "scientist". I think if you want to include people who categorize themselves as creation scientists, then that would not be a true statement. I know that some of those do not agree.

As far as my colleagues, geologists, geochemists, geophysicists and paleontologists, the ones that I know of, I don't know of any who disagree that the earth is very old or that radiometric dating is not a good way to date the earth.

Q: Are you aware of any creation scientist, then, who

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Q: (Continuing) has published evidence in the open scientific literature who has questioned the fundamental premises of geochronology by radioactive dating?

A: I know of one.

Q: Who is that?

A: That's Robert Gentry. I should say that Robert Gentry characterizes himself as a creation scientist, if I understand what he's written.

Q: Are you familiar with Paul Damon?

A: Yes. I know him personally.

Q: Who is Mr. Damon?

A: Mr. Damon is a professor at the University of Arizona at Tucson. He specializes in geochronology.

Q: Are you aware that Mr. Damon has stated in a letter that if Mr. Gentry's work is correct, that it casts in doubt that entire science of geochronology?

A: Which letter are you referring to?

Q: Do you recall the letter which you gave to me from EOS by Mr. Damon?

A: Yes. I recall the general nature of that letter.

Q: And do you recall that Mr. Damon said that if history is correct, in his deductions it would call up to question the entire science of geochronology?

A: Well, I think that's the general sense of what Paul Damon said, but I think it's an overstatement. I'm not

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A: (Continuing) sure I would agree with him on that.

Q: Mr. Damon is not a creation scientist, is he?

A: No. Doctor Damon is not a creation scientist, by any means.

Q: Would you consider him to be a competent scientist and an authority in this field?

A: Yes. He's extremely competent.

Q: Are you aware as to whether Mr. Gentry has ever offered or provided a way for his evidence to e falsified?

A: I am aware that he has proposed one, but I do not think his proposal would falsify it either one way or the other.

Q: Have you ever made any attempts, experiments that would attempt to falsify his work?

A: Well, there are a great many- I guess you're going to have to tell me specifically what you mean by "his work". If you could tell me the specific scientific evidence you're talking about, then let's discuss that.

Q: Well, first of all, do you like to think you keep current on the scientific literature as it may affect geochronology?

A: Well, I keep as current as I can. There's a mass amount of literature. In the building next to my office, there are over two hundred fifty thousand volumes, mostly on geology. It's extremely difficult to keep current.

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A: (Continuing) But I am currently relatively up on the mainstream, anyway.

Q: Certainly the most important points?

A: I do my best.

Q: And if someone had issued a study which would, if true, call up to question the entire science of geochronology, would you not want to be made aware of that and look at that closely yourself, as an expert in the field?

A: Oh, yes, I would.

Q: And as a matter of fact, your familiarity with Mr. Gentry's work is limited, is it not, to an article that he wrote in 1972 and a letter that he wrote in response to Mr. Damon's letter, in terms of what you have read, is that correct?

A: Those are the things I can recall having read, and the reports that I have some recollection of. I have never been terribly interested in radioactive haloes, and I have not followed that work very closely. And that is the subject upon which Mr. Gentry has done most of his research.

As I think I told you in the deposition, I'm not an expert on that particular endeavor. I'm aware that Mr. Gentry has issued a challenge, but I think that challenge is meaningless.

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Q: Well, let me ask you this. You stated in the deposition, did you not- Let me ask you the question, can, to your knowledge, granite be synthesized in a laboratory?

A: I don't know of anyone who has synthesized a piece of granite in a laboratory. What relevance does that have to anything?

Q: I'm asking you the question, can it be done?

A: Well, in the future I suspect that it will be done.

Q: I understand. But you said it has not been done yet?

A: I'm not aware that it has been done. It's an extremely difficult technical problem, and that's basically what's behind it.

Q: To the extent that you are familiar with Mr. Gentry's work and that as you have reviewed it, would you consider him to be a competent scientist?

A: I think Mr. Gentry is regarded as a competent scientist within his field of expertise, yes.

Q: And you would agree with that?

A: From what I've seen, that's a fair assessment of his work, yes. He's a very, did some very careful measurements, and by and large he comes to reasonable conclusions, I think, with the possible exception of what we're hedging around the fringes here, and that is his experiment to falsify his relatively recent inception of

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A: (Continuing) the earth hypothesis. We have not really discussed what his hypothesis is and what his challenge is, we've sort of beat around the edges.

Q: Well, you haven't read his articles that he wrote since 1972, have you?

A: No. That's true.

Q: So if his hypothesis were in those articles, you really wouldn't be able to talk about it, at any rate, would you?

A: His hypothesis, I believe, is pretty fairly covered In those letters between, exchange of letters between Damon and Gentry, and I can certainly discuss that part.

That's a very current exchange of letters. It is just a few years old. And it is in that letter that he throws down to challenge to geology to prove him wrong. What I'm saying is, that challenge is meaningless.

Q: Are you familiar with his studies of radio haloes?

A: No, I'm not familiar with that work at all.

Q: But to the extent that work shows that evidence that these formations are only several thousand years old, you're not familiar with that?

A: I'm not familiar with that, and I'm not sure I would accept your conclusion unless I did look into it.

Q: If you're not familiar with it, I don't want to question you about something you're not familiar with.

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A: Fair enough.

Q: You have been active, of late, have you not, in trying to formulate a resolution against creation science in one of the professional societies to which you belong?

A: That's true. The American Geophysical Union.

Q: How do you go about writing that? Did you just sit down and try to write something yourself?

A: No. I requested from Bill Mayer copies of the resolutions holding the teaching of creation science as science in the classroom last March, so that I could see the general form and tone of resolutions that had already been passed by other principal scientific societies, including the National Academy of Sciences. He sent me, I believe, copies of about eight or nine.

And after reading through those, I drafted a proposal which was sent around to members of the Council of the American Geophysical Union. That proposal was discussed, the resolution was modified, and a much abbreviated resolution was adopted Sunday night.

Q: I think you stated earlier that you reviewed quite a bit of creation-science literature in preparation for your testimony in this case and also a case in California, is that correct?

A: Yes. I think I've read either in whole or in part about two dozen books and articles.

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Q: But on the list of books that you made or articles that you have reviewed, you did not include any of Robert Gentry's work as having been reviewed, did you?

A: That's right. I did not.

Q: Although you consider Gentry to be a creation scientist?

A: Well, yes. But, you know, the scientific literature and even the creation science literature, which I do not consider scientific literature - It's outside the traditional literature - there is an enormously complex business. There is a lot of it. And we can't review it all.

Every time I review even a short paper, it takes me several hours to read it, I have to think about the logic involved in the data, I have to reread it several times to be sure I understand what the author has said; I have to go back through the author's references and sometimes read as many as twenty or thirty papers that the author has referenced to find out whether what has been referenced is true or makes any sense; I have to check the calculations to find out if they are correct. It's an enormous job. And given the limited amount of time that I have to put in on this, reviewing the creation science literature is not a terribly productive thing for a scientist to do.

Q: How many articles or books have you reviewed,

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Q: (Continuing) approximately?

A: You mean in creation science literature?

Q: Creation science literature.

A: I think it was approximately twenty-four or twenty-five, something like that, as best I can remember. I gave you a complete list, which is as accurate as I can recall.

Q: And if there were articles in the open scientific literature - Excuse me - in referee journals which supported the creation science model, would that not be something you would want to look at in trying to review the creation science literature?

A: Yes, and I did look at a number of those. And I still found no evidence.

Q: But you didn't look at any from Mr. Gentry?

A: No, I did not. That's one I didn't get around to. There's quite a few others I haven't gotten around to. I probably never will look into all the creationists literature.

I can't even look into all the legitimate scientific literature. But I can go so far as to say that every case that I have looked into in detail has had very, very serious flaws. And I think I've looked at a representative sample.

And also in Gentry's work, he's proposed a very tiny

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A: (Continuing) mystery which is balanced on the other side by an enormous amount of evidence. And I think it's important to know what the answer to that little mystery is. But I don't think you can take one little fact for which we now have no answer, and try to balance, say that equals a preponderance of evidence on the other side. That's just not quite the way the scales tip.

Q: If that tiny mystery, at least by one authority who you acknowledge his authority, has been said, if correct, call to question the entire science of geochronology.

A: Well, that's what Damon said. And I also said that I did not agree with Paul Damon in that statement. I think that's an overstatement of the case by a long way. I think that Paul in that case was engaging in rhetoric.

Q: What is your personal belief as to the existence of a God?

A: Well, I consider my religion a highly personal matter, and I've never required personally anything other than explaining the world we see around us by natural events. But I try to remain rather open minded on the subject.

So I guess at best I can tell you that I have not come to any firm conclusion that I am not willing to change in the future.

Q: (Continuing) would be something between an agnostic and an atheist; is that correct?

A: No. I said about halfway between an agnostic and an atheist. But the reason I said that was because you were trying to get me to label myself. And I think I also said that I do not label myself. But you were insistent that I give you some answer on that scale, and I'm afraid that's the best I can do. I'm not happy with that answer, but I simply can't do any better.

Q: But you also stated, did you not, that you had not seen any proof of a God?

A: I think I did say that. Yes.

Q: Nonetheless, you would agree that a religious person can be a competent scientist?

A: Absolutely, and I know a number of them.

MR. WILLIAMS: No further questions, Your Honor.

REDIRECT EXAMINATION

BY MR. ENNIS:

Q: Doctor Dalrymple, Mr. Williams asked you about a resolution of the American Geophysical Union. What is the American Geophysical Union?

A: The American Geophysical Union is the largest society of physicists- Well, let me take that back. I think it's one of the largest societies of geophysicists

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A: (Continuing) in North America. The American Society for Exploration of Geophysicists may be larger. I'm not sure.

It consists of a variety of sections that include scientists working on geochemistry, seismology, petrology, hydrology, planetology, astronomy, meteorology, upper atmosphere physics, and so forth. Anything to do with the physics and chemistry of the earth is included in the American Geophysical Union.

Q: Mr. Williams brought out on his cross examination that you had worked on a proposed resolution to be considered by the American Geophysical Union on this subject, is that correct?

A: Yes, I have.

Q: And he brought out that in the course of working on that resolution, you asked to see if other scientific organizations had adopted resolutions on teaching of creation science in public schools?

A: That's correct.

Q: What other resolutions did you obtain from which other organizations?

A: Well, I'm not sure I can remember them all. They were mostly biological societies. There was the National Association of Biology Teachers, there was the National Academy of Sciences, the American Association for the

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A: (Continuing) Advancement of Sciences has a resolution, and there were five or six others whose names I don't remember at the moment. They are all included in the material I think I gave to Mr. Williams.

Q: These are other scientific organizations that have adopted resolutions opposing the teaching of creation science in public schools?

A: Yes. They have opposed the teaching of creation science as science. I want to e very specific about that. Most organizations are not opposed to teaching it as a part of a social science curriculum.

Q: Do you have the power or authority by yourself to issue a resolution on behalf of the American Geophysical Union?

A: No, of course not. I can only submit one to the Council for approval.

Q: And you testified during cross examination that on December 6th the Council of the American Geophysical Union did, in fact, adopt a resolution, is that correct?

A: Yes. It was Sunday night, if that was December 6th.

Q: I'd like to show you a document and ask you if that document reflects the resolution adopted by the American Geophysical Union?

A: Yes, that is the resolution.

Q: Could you please read it for the record?

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A: Yes, I will. It's preceded by the following statement. It says: "The final resolution was passed unanimously by the Council of the American Geophysical Union on Sunday, December 6, 1981."

Then the resolution reads as follows: "The Council of the American Geophysical Union notes with concern the the continuing efforts by creationists for administrative, legislative, and political action designed to require the teaching of creationism as a scientific theory.

"The American Geophysical Union is opposed to all efforts to require the teaching of creationism or any other religious tenets as science."

That's the end of the resolution.

MR. ENNIS: Your Honor, I would like to move that that resolution be received in evidence as a plaintiffs' exhibit.

THE COURT: It will be received.

MR. ENNIS: Do we know which number it will be assigned?

THE COURT: I don't.

MR. ENNIS: We'll take care of that detail later.

MR. ENNIS: (Continuing)

Q: Doctor Gentry, Mr. Williams asked you some questions-

A: Doctor who?

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Q: Doctor Dalrymple. Mr. Williams asked you some questions about Mr. Gentry's hypothesis. Are you familiar with that hypothesis?

A: Well, I'm familiar with it if it is accurately represented in the exchange of letters published in EOS between Mr. Gentry and Doctor Damon.

Q: Does Mr. Gentry's hypothesis depend upon supernatural causes?

A: Yes, it does.

Q: Could you explain, please?

A: Well, I think it might be best explained if I could simply read his two statements from his letter, and then I won't misquote him, if that would be permissible.

Q: Do you have that with you?

A: No, I don't, but it was supplied in the material that I gave in my deposition.

MR. ENNIS: I have been informed that we can mark the resolution of the American Geophysical Union as Plaintiffs' Exhibit Number Twenty-eight.

THE COURT: It will be received.

A: Yes, I have it now.

Q: Doctor Dalrymple, would you please read from that document, after describing what it is?

A: Yes. It's just a couple of sentences. It's State's Exhibit Number Nine, is the way it's marked. It's two

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A: (Continuing) letters that appeared, actually three letters that appeared in a column for that purpose in EOS. EOS is the transactions of the American Geophysical Union. It's a newsletter in which letters like this are commonly exchanged.

It's Volume 60, Number 22; May 29, 1979, page 474. In Mr. Gentry's response to Doctor Damon, he makes the following statement: "And as far as a new comprehensive theory is concerned, I would replace the once singularity of the Big Bang with two major cosmos-related singularities (in which I exclude any implications about extraterrestrial life-related phenomena) derived from the historic Judeo-Christian ethic, namely the events associated with (1) the galaxies (including the Milky Way) being Created ex nihilo by Fiat nearly 6 millennia ago and (2) a later catastrophe which resulted in a solar system-wide disturbance that was manifested on earth primarily as a worldwide flood with subsequent crustal adjustments."

And then he goes on.

Q: During cross examination Mr. Williams asked you if Mr. Gentry's argument or hypothesis could be falsified. Has Mr. Gentry proposed a method for falsifying his hypothesis?

A: Yes, he has proposed a test and that is the one I

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A: (Continuing) characterized as meaningless.

Q: Why would it be meaningless?

A: Let me first see if I can find a statement of the test, and I will explain that. I have it now.

THE COURT: May I read what you quoted from the newsletter before you go to that?

Okay, sir.

A: The experiment that Doctor Gentry proposed-

THE COURT: Let me ask you a question. As I understand it, that's his conclusion. I still don't understand what his theory is.

THE WITNESS: He has proposed that it is either a theory or a hypothesis that he says can be falsified.

THE COURT: What's the basis for the proposal? How does he come up with that?

THE WITNESS: Well, basically what he has found is there is a series of radioactive haloes within minerals in the rocks. Many minerals like mica include very tiny particles of other minerals that are radioactive, little crystals of zircon and things like that, that have a lot of uranium in them.

And as the uranium decays, the alpha particles will not decay, but travel outward through the mica. And they cause radiation damage in the mica around the radioactive particle. And the distance that those particles travel is

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THE WITNESS: (Continuing) indicated by these radioactive haloes. And that distance is related directly to the energy of the decay. And from the energy of the decay, it is thought that we can identify the isotopes.

That's the kind of work that Gentry has been doing.

And what he has found is that he has identified certain haloes which he claims are from Polonium-218. Now, Polonium-218 is one of the isotopes intermediate in the decay chain between uranium and lead.

Uranium doesn't decay directly from lead. It goes through a whole series of intermediate products, each of which is radioactive and in turn decays.

Polonium-218 is derived in this occasion from Radon 222. And what he has found is that the Polonium haloes, and this is what he claims to have found, are the Polonium-2l8 haloes, but not Radon-222 haloes. And therefore, he says that the Polonium could not have come from the decay of Radium, therefore it could not have come from the normal decay change.

And he says, how did it get there? And then he says that the only way it could have gotten there unsupported Radon-222 decay is to have been primordial Polonium, that is Polonium that was created at the time the solar system was created, or the universe.

Well, the problem with that is Polonium-2l8 has a

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THE WITNESS: (Continuing) half-life of only about three minutes, I believe it is. So that if you have a granitic body, a rock that comes from the melt, that contains this mica, and it cools down, it takes millions of years for body like that to cool.

So that by the time the body cooled, all the Polonium would have decayed, since it has an extremely short half-life. Therefore, there would be no Polonium in the body to cause the Polonium haloes.

So what he is saying, this is primordial Polonium; therefore, the granite mass in which it occurs could not have cooled slowly; therefore, it must have been created by fiat, instantly.

And the experiment he has proposed to falsify this is that he says he will accept this hypothesis as false when somebody can synthesize a piece of granite in the laboratory.

And I'm claiming that that would be a meaningless experiment.

Does that- I know this is a rather complicated subject.

THE COURT: I am not sure I understand all of this process. Obviously I don't understand all of this process, but why don't you go ahead, Mr. Ennis?

MR. ENNIS: Yes, your Honor. Obviously, your Honor, these subjects are somewhat complex, and if the Court has

Q: Why, in your opinion, would the test proposed by Mr. Gentry not falsify his hypothesis?

A: Let me read specifically first what his proposal is. He said, "I would consider my thesis essentially falsified if and when geologists synthesize a hand-sized specimen of a typical biotite barium granite and/or a similar sized crystal of biotite."

And if I understand what he's saying there, he's saying that since his proposal requires that granite form rapidly, instantly, by instantaneous creation, that he does not see any evidence that these granites, in fact, cool slowly; his evidence said they cool rapidly. And he would accept as evidence if somebody could synthesize a piece of granite in the laboratory.

There are a couple of problems with that. In the first place, we know that these granites did form slowly from a liquid from the following evidence: These rocks contain certain kinds of textures which are only found in rocks that cool from a liquid. And we can observe that in two ways, these textures. They are called igneous and crystalline textures.

We can observe these textures by crystallizing compounds

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Page is missing.

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A: (Continuing) a liquid. There is no other way that they could have formed.

The other problem with Gentry's proposal is that the crystallization of granite is an enormously difficult technical problem, and that's all it is. We can't crystallize granite in the laboratory, and he's proposing a hand-sized specimen. That's something like this, I presume.

In the first place, the business of crystallizing rocks at temperatures, most of them crystallize at temperatures between seven hundred and twelve hundred degrees centigrade. The temperatures are high. And in the case of granites and metamorphic rocks, sometimes the pressures are high, many kilobars. So it takes a rather elaborate, sometimes dangerous apparatus to do this.

And the apparatus is of such a size that usually what we have to crystallize is very tiny pieces. I don't know of anyone who has developed an apparatus to crystallize anything that's hand-sized.

So he's thrown down a challenge that's impossible at the moment, within the limits of the present technical knowledge.

The second thing is that the crystallization of granite, the reason we have not been able to crystallize even a tiny piece in the laboratory that I know if, unless there

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A: (Continuing) has been a recent breakthrough, is essentially an experimental one. It's a kinetic problem.

Anyone who has tried to grow crystals in a laboratory knows that it's very difficult to do if you don't seed the melt. That is, you have to start with some kind of a little tiny crystal to begin with. And when the semi-conductor industry, for example, grows crystals to use in watches like this, they always have to start with a little tiny seed crystal. And once you have that tiny seed crystal, then you can get it to crystallize.

So it's basically a problem of getting the reaction to go, it's a problem of nucleation, getting it started, and it's a problem of kinetics, getting the reaction to go on these viscous melts that are very hot under high pressure.

And what I'm saying is that even if we could crystallize a piece of hand-sized granite in the laboratory, it would prove nothing. All it would represent would be a technical breakthrough. All of a sudden scientists would be able to perform experiments that we cannot now perform.

But in terms of throwing down a challenge to the age of the earth, that's a meaningless experiment. So he's thrown down a challenge that has no meaning, hand-sized crystallized granite. And he's saying, `If you don't meet it, then I won't accept your evidence.' Well, it's a meaningless challenge. It's not an experiment.

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Q: Doctor Dalrymple, if I understand correctly, Polonium-218 is the product of the radioactive decay of Radon-222, is that correct?

A: Yes, that's correct.

Q: And does Polonium-218 occur through any other process?

A: Not as far as I know. I suspect you could make it in a nuclear reactor, but I don't know that. I'm not sure, but I don't think Polonium-2l8 is a product of any other decay chain.

Q: So if there were Polonium-218 in a rock which did not have any previous Radon-222 in that rock, then that existence of Polonium-218 would mean that the laws of physics as you understand them would have had to have been suspended for that Polonium to be there; is that correct?

A: Well, if that were the case, it might or it might not. But there are a couple of other possibilities. One is that perhaps Gentry is mistaken about the halo. It may not have been Polonium-218. The second one is that it's possible that he's not been able to identify the Radon-222 halo. Maybe it's been erased, and maybe for reasons we don't understand, it was never created.

This is why I say It's just a tiny mystery. We have lots of these in science, little things that we can't quite explain. But we don't throw those on the scale and

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A: (continuing) claim that they outweigh everything else. That's simply not a rational way to operate.

I would be very interested to know what the ultimate solution to this problem is, and I suspect eventually there will be a natural explanation found for it.

Q: Does Mr. Gentry's data provide scientific evidence from which you conclude that the earth is relatively young?

A: Well, I certainly wouldn't reach that conclusion, because that evidence has to be balanced by everything else we know, and everything else we know tells us that it's extremely old.

The other thing that I should mention, and I forgot to make this in my previous point, if I could, and that is that Mr. Gentry seems to be saying that the crystalline rocks; the basic rocks, the old rocks of the contents were forms instantaneously. And he uses granite.

But the thing that he seems to overlook is that not all these old rocks are granites. In fact, there are lava flows included in those old rocks, there are sediments included in those old rocks. These sediments were deposited in oceans, they were deposited in lakes. They are even pre-Cambrian glacial deposits that tells that the glaciers were on the earth a long, long time ago.

So it's impossible to characterize all of the old crystalline rocks as being just granite. Granite is a

A: (Continuing) very special rock type, and it makes up a rather small percentage of the pre-Cambrian or the old crystalline rocks that formed before the continents.

MR. ENNIS: May I have one moment, your Honor?

THE COURT: Sure.

MR. ENNIS: No further questions, but I would like to state for the record, I have now been informed that Exhibit 28 was not an available number for exhibits, so if we could remark the resolution of the American Geophysical Union with the exhibit number 122 for plaintiffs. I believe that is an available number.

THE COURT: Mr. Williams, do you have any more questions?

MR. WILLIAMS: Briefly, your Honor.

May I approach the witness, your Honor?

THE COURT: Yes.

MR. WILLIAMS: Inasmuch as the witness is quoting from this letter, I would like to have it introduced into evidence so that it can be read in the context, these two pages from Forum EOS dated May 29, 1979. We could make these Defendant's Exhibit 1.

THE COURT: Okay.

MR. WILLIAMS: I'll have it marked.

RECROSS EXAMINATION

BY MR. WILLIAMS:

Q: You state that the challenge which Mr. Gentry has

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Q: (Continuing) issued, if I understand you, is essentially impossible?

A: It is presently impossible within our present technical capability. There have been people working on this, and I suspect someday we'll be able to do it.

Q: Is it not true that you can take a pile of sedimentary rocks and by applying heat and pressure just simply convert that to something like a granite?

A: Something like a granite, yes, that's true. But it's something like a granite, but they have quite different textures. When you do that, you now have a metamorphic rock, and it has a different fabric, and it has a different texture, which is quite distinct from a igneous texture. They are very easily identified from both a hand specimen and a microscope. Any third year geology student could tell you if you handle a piece of rock whether it's igneous or metamorphic. It's a very simple problem.

Q: But it is quite similar to a granite, but you just can't quite get it to be a granite, can you?

A: Well, granite sort of has two connotations. In the first place, in the strict sense, granite is a composition only. It's a composition of an igneous rock. Granite is a word that we use for rock classification.

It is also used in a looser sense, and that looser sense

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A: (Continuing) includes all igneous rocks that cool deep within the earth. And they would include things like quartz, diorite- I won't bother to tell you what those are, but they are a range of composition.

Sometimes granite is used in that loose sense. People say that the Sierra Nevada is composed primarily of granite. Well, technically there is no granite in the Sierra Nevada. They are slightly different compositions.

It is also used to describe the compositions of certain types of metamorphic rocks. So you have to be a little careful when you use the term `granite' and be sure that we know exactly in what sense we are using that word.

Q: Now, you stated that you think, in trying to explain why Gentry's theory might not be correct or not that important, you said that perhaps he misidentified some of the haloes, and I think you also said that perhaps he had mismeasured something, is that correct?

A: Well, I think those were the same statement. I'm just offering that as an alternative hypothesis.

Q: Do you know that's what happened?

A: Oh, no, no.

Q: You have not made any of these studies and determined that yourself, have you?

A: No, no.

Q: We've already had testimony in the record, Doctor

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Q: (Continuing) Dalrymple, in this case yesterday from another of plaintiffs' witnesses that science is not concerned with where a theory comes from, a model comes from, it's concerned with whether the data fit the model. Would you agree with that?

A: Well, I think that that sounds like a fair statement, yes. If you mean by that that we don't really care who proposes it. Is that- I'm not sure I understand the sense of your question. That's the way I took it anyway.

Do you mean that is anyone eligible to propose something like that and will it be considered?

Q: Not just who proposes it, but the source from which they get it or their motivation. Those aren't important. The important thing is that the data fit what has been proposed.

A: Well, the motivation might be important. For example, I think we went over this in the deposition a little bit. You don't just simply propose a theory. What you really propose is a hypothesis or something smaller in scale. A: theory only becomes accepted as a theory in the scientific theory when there is a large amount of evidence - I would characterize it as a preponderance of evidence - to support that theory.

That doesn't necessarily mean that it's right. At some time in the future it may have to be modified. But we

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A: (Continuing) don't just characterize any idea as a theory. I think we start with something much less tentative. And even a hypothesis is usually proposed to explain some set of facts so that- One thing we're not allowed to do in science is to let any kind of belief or prejudice drive our hypotheses or theories. We're not supposed to become personally involved in them.

And this is why I say that motivation might be important. We are not out to prove our personal beliefs. What we're out to do is seek the truth within the limited framework within which science operates.

So that's why I say that motivation might be important. If someone is out to prove something for their own benefit, then their motivation might come into it.

Q: If someone had proposed, for example, a theory or hypothesis motivated by their own political ideology, would you be concerned about that, as long as the data fit the hypothesis or the theory?

A: I think as long as the data, if it was proposed on a reasonable basis, on the basis of existing data, then I think in a case like that, that would be perfectly acceptable. As long as the motivation was truly divorced from the hypothesis, then I would have no problem with it.

Q: By the way, you differentiated between a hypothesis and a theory. Is it true that a hypothesis is something

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Q: (Continuing) more tentative, in your mind, and a theory is perhaps more established, and at some point a theory becomes a fact?

A: No, I don't put them together in quite that difference, but I'll explain to you as best I can what my notion of those terms are.

I think a fact - facts are data. That's the way I consider facts. A fact is if we measured the length of this box a number of times and determined that it's three and a half feet long, then that becomes a relatively indisputable fact.

There is a difference, in my mind, between a theory and a hypothesis, both in scale and in the degree of proof behind it. I think a hypothesis can be a relatively small thing. We might again hypothesize that this box is three and a half feet long, and we could test that hypothesis by making measurements and find out whether that is true or false. That could be a reasonable hypothesis.

Or it might be bigger. After it become rather firmly established, after there is a lot of evidence for it, then it is adopted as a theory. And I think if you look in places like Webster's Dictionary, I think you will find that there is a distinction made there in the degree of tentativeness.

Theories are fairly firmly established things. Now,

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A: (Continuing) sometimes we find that they are not true and have to modify them, but there is this degree of scale between hypothesis and theory.

Q: For example, Copernicus proposed a theory, did he not-

MR. ENNIS: Your Honor, I didn't object earlier to this line of questioning, but I think it's entirely outside the scope of my redirect examination.

THE COURT: Well, I don't think it's limited by that, or it wouldn't be as far as I'm concerned, but where are you going with it?

MR. WILLIAMS: Your Honor, I think I'm going, this particular line of testimony is important to show that there is perhaps not an accord among even the Plaintiffs' scientists as to what is a fact, what's a theory, what's a hypothesis.

And I think it goes to the fact that there is no unanimity on these things, even among the plaintiffs' own scientists. I think that has some relevance at least to the argument which the plaintiffs are making as to whether this is a scientific theory in looking at creation science.

THE COURT: Well, I would take notice that there's probably not unanimity among all the scientists.

MR. WILLIAMS: Fine.

MR. WILLIAMS: (Continuing)

Q: As part of Defendants' Exhibit 1, Mr. Gentry quotes

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Q: (Continuing) from a National Academy of Science Resolution of April of 1976, which reads in part: "That the search for knowledge and understanding of the physical universe and of living things that inhabit it should be conducted under conditions of intellectual freedom, without religious, political, or ideological restrictions. That freedom of inquiry and dissemination of ideas require that those so engaged should be free to search where their inquiry leads, without political censorship and without fear of retribution and consequence of unpopularity of their conclusions. Those who challenge existing theory must be protected from retaliatory reactions."